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2019 (7) TMI 806 - GUJARAT HIGH COURTReopening of assessment u/s 147 - Validity of reasons to believe - notice issues beyond period of four years - HELD THAT:- Initiation of reassessment proceedings under Section 143(3) of the Act had been made beyond the period of four years by issuing notice under Section 148 of the Act without any allegation that the income chargeable to tax had escaped assessment for such assessment year by reason of the failure on the part of the assessee to disclose fully and truly all the material facts necessary for his assessment for that assessment year. The Tribunal, while concurring findings recorded by the CIT(A) clearly held that the initiation of reassessment proceedings under Section 147 of the Act was bad in law. - Decided in favour of assessee.
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